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Fine for trust office Athos Business Services (Netherlands) B.V. for insufficient customer due diligence

Enforcement measures

De Nederlandsche Bank (DNB) imposed an administrative fine of €10,000 on trust office Athos Business Services (Netherlands) B.V. (Athos). The fine was imposed because Athos provided trust services without carrying out sufficient customer due diligence.

Published: 26 September 2023

Toorop Gebouw Entree


Trust offices may not enter into a business relationship or provide a trust service until customer due diligence has been carried out that meets the statutory requirements as set out in the Act on the Supervision of Trust Offices 2018 (Wet toezicht trustkantoren 2018 – Wtt 2018)

Upon examination of two high risk customer files, we found that the customer due diligence carried out by Athos did not meet the requirements of the Wtt 2018 before it started providing its trust services. As a result, there were doubts about the accuracy or completeness of the customer due diligence, even though Athos did provide trust services to these two customers. This is in non-compliance with the law.

We have imposed a fine on Athos for this non-compliance, which is subject to a basic fine amount of €2,500,000. Given Athos' size and ability to pay, we reduced this amount to €10,000.


The Wtt 2018 aims to promote the integrity of the financial system through regulation of the trust sector. Trust offices act as gatekeepers of the system. By conducting ongoing customer due diligence, including prior to entering into a business relationship, trust offices play an important role in countering terrorist financing and criminal money laundering. Athos failed to fulfil its obligation to conduct proper customer due diligence before it started to provide its trust services, thus compromising the objectives of the Wtt 2018.


Any interested party may lodge an objection against this decision within six weeks of its date.

Further information

The full text of the decision can be found here. For more information, please contact our Information Desk on 0800 -020 1068 (freephone in the Netherlands) or +31 20 524 9111 (if you call us from abroad)

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Further appeal



Decision on objection


Decision given


Decision given

18 September 2023








Boete- en openbaarmakingsbesluit Athos Business Services (Netherlands) B.V. (Dutch only)

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